(a)
A formal advisory opinion,
(1)
Which involves the application of any conflict of interest law embodied in 18 U.S.C. 202-209 to a transaction or activity which does not raise a question of an actual or apparent violation of this law but which raises an important matter of first impression, or
(2)
Which is issued following the procedure set forth in § 2638.305(d) ,
requires consultation by the Office of Government Ethics with the Office of Legal Counsel of the Department of Justice before it is issued.
(b)
An advisory opinion shall be considered issued when it is dated, numbered, and signed by the Director. Unless released by the person who made the request, the opinion will not become publicly available until information which identifies individuals involved and which is unnecessary to the complete understanding of the opinion has been deleted from the opinion and this version of the opinion is placed in a public reading file at the Office of Government Ethics. (See § 2638.310 )